by Eric J. de Silva
I
refer to Dr. Mahinda de Silva (MdeS)’s response of 22nd January
to my article which appeared in The Island on 16th January under
the title ‘The debate on generic drugs – a layman’s point of
view’. MdeS seems obviously peeved that a layman has entered a
debate which should be left in the hands of medical
professionals, without realizing who the key stakeholders in
this vital discourse are. He would rather like lay men and women
to shut up! (Hence, epithets like Don Quixote!)
Incidentally, let me say I never introduced myself as "the
public’s appointed spokesman" as he tries to make out, by using
those words within quotes. I did say I represent the public
interest, adding the words "as perhaps their self-appointed
spokesman!" within parenthesis. Not many would have failed to
see the difference!
The problem of definitions
In his very first intervention in this debate (9th January),
Dr.MdeS defined a generic drug as "an exact copy of a brand name
drug whose patent has expired", which he admits to have modified
in the second article he wrote on the subject. What is
significant, anyway, is that he does not contest the Merck
Manual classification that I brought to the notice of the
reader, according to which there are three names associated with
drugs viz.(i) chemical name, (ii) generic (official) name and
(iii) trade (proprietary or brand) name.
Yet, he proceeds to accuse me of taking the Merck definition
too literally, as if definitions can be taken metaphorically or
figuratively! I am not aware that they do so in the medical
profession! These are his words,: "Quoting from his Merck
Manual’s definition of a generic drug, Mr. EdeS sees a
difference from my definition, which is causing him confusion.
Of course, he does not have the insight to wonder whether he
might be misrepresenting what his Merck Manual says, by taking
its information too literally". I do not, of course, claim to
have the "insight to wonder" which he seems to have in
abundance, making him see no difference between the Merck Manual
definition and his own which says "the chemical name = the
generic name".
Since Dr. MdeS, with 23 years of experience as a medical
practitioner in USA, has repeatedly referred to the Federal Drug
Authority (FDA) of that country, and has patronizingly suggested
that I log on to the internet myself "or with the aid of
another", let me quote for his benefit and that of the readers
what the FDA Consumer Magazine (July-August 2005) says on the
subject of Drug Name Confusion, with emphasis added:
"Every drug usually has three names: chemical, generic
(non-proprietary), and brand (proprietary) names, and each is
subject to different rules and regulations.
The chemical name specifies the chemical structure of the
drug. It is not preapproved by any organization, nor is it
recognized in any standard manuals, such as USP publications.
Therefore, chemical names are primarily used by researchers, but
not in medical practice.
The FDA requires that either the established, or official,
name or in the absence of an official name, the common or usual
name, appears on labels and labeling of a drug product. The
common name, loosely referred to as the generic name, must
accompany the brand name, if there is one ……….
The generic name is usually created for drug substances when
a new drug is ready for marketing. It is selected by the United
States Adopted Names (USAN) Council, whose expertise is
recognized by the FDA, according to principles developed to
ensure safety, consistence, and logic. These names are typically
used by health care professionals.
Generic names are coined using an established stem, or group
of letters that represents a specific drug class……………….Names
that include such stems , chemistry roots, or any other coded
information are easier to remember, and give clues about what a
drug is used for.
The brand name, also called trademark, can be created as soon
as a generic name has been established. Only brand names of
products subject to a new drug application or an abbreviated new
drug application must be approved by the FDA first. This
requirement distinguishes them from generic names."
This should help us to lay at rest the debate on definitions,
and move on to the larger issue which Dr. D.P. Atukorale (DPA)
brought to our attention and has, since then, generated a lot of
hot air. The question is how will the government’s decision to
compel doctors to prescribe drugs by their generic names, hailed
by my friend Prof. Carlo Fonseka (CF) as a "giant step to be
taken by Hon. Nimal Siripala de Silva", impact on their lives?
Generic prescribing does not, naturally, pose major problems
in a country like US in view of their strict regulatory
arrangements to ensure the quality of both the generic and
branded drugs that come into the market, well-trained
pharmacists, and greater rapport between the pharmacist and the
doctor which enables the pharmacist to even consult the doctor
before dispensing a prescription. "But that is in the United
States, and we are here in Sri Lanka" as I said in my previous
intervention.
The Sri Lankan situation
As for Sri Lanka, MdeS refers to our DRA (Drug Regulatory
Authority)’s failure to perform its basic function "either due
to incompetence, malfeasance or both", and "the regulatory
anarchy" that prevails as a result. He emphasizes that any drug
approved by the DRA should be of the same quality, and as safe
and effective as the brand drug (by this he appears to mean the
original innovator drug). Having said that, he wonders whether
it would not be wise for government to be the main if not the
sole importer of essential drugs, given a competent and honest
DRA without a conflict of interest, which is nowhere in the
horizon!
Then he says that the DRA does not itself test drugs for
quality. Neither can a National Quality Control lab be expected
to have the ability to test the quality of myriads of drugs in
the market, he says. He does not say whether such a lab would be
able to do this if the number of drugs is reduced to a
manageable number, as he himself suggests elsewhere. Then he
proceeds to say "complaints regarding quality are directed to
the DRA and the manufacturer who are the institutions that can
resolve them" all of which make the DRA look like an
intermediary and the manufacturer himself the final arbiter on
quality. Thereafter he says that the manufacturer must supply
the scientific and technological data to the scientists and
technologists at the DRA who will pronounce on the quality of
the drug! Those who have the "insight to wonder" may be able to
make some sense out of all this!
In an article written to the Daily Mirror (23rd January),
MdeS has expressed the hope that the debate on generic drugs is
brought to a conclusion with the information he has supplied to
that newspaper, which I find is no different from what he had
said through the columns of The Island. It is my honest belief
that he has not done much to enlighten us on the merits and
demerits of the government decision, and the debate is still
open.
Helping the poor, or hitting them?
DPA, in his latest piece in The Island (25th January),
re-iterates that almost all the drugs used in our hospitals
(both government and private) and the majority of drugs sold in
our pharmacies including SPC are branded drugs; and that generic
unbranded drugs (which he calls pure generics) are just a few.
He also says, not for the first time, that most of the brand
drugs that are available are of poor quality, and that we do not
have facilities to test the quality of most of these. This is
where a large part of the problem lies, and this is what Prof
Sanath P. Lamabadusuriya so succinctly pointed out. Have the
government’s official and unofficial advisers given attention to
this? Why have Dr. Balasubramaniam and Prof. Carlo Fonseka got
into a shell after their initial outburst? They should be able
to answer the questions that agitate the public mind better than
MdeS whose experience is more in US!
It is well known that a lot of generic unbranded and generic
branded drugs are imported to this country from other South
Asian countries. If you take India as an example there are high
quality generic brands which doctors do freely prescribe instead
of the innovator trade name drug. On a personal note, two of the
three drugs that I presently take on a daily basis are
manufactured in India. But that is not the end of the story. It
is well known that drugs of poor or doubtful quality are made
not only in India, but also in other countries from which we
import. D.G.Dassanayake, an Island reader, says (27th January)
he saw antibiotic capsules being ‘assembled’ inside houses
during a visit to a South Indian low income urban community
recently. No wonder the Indian government was concerned about
spurious/ counterfeit/ substandard drugs made there, and
appointed an Expert Committee a couple of years back to examine
and report on all aspects of the problem. This Committee (known
as the Mashelkar Committee) reported on serious inadequacies in
the regulatory arrangements obtaining in India. Can those who
have rushed in to applaud the recent decision taken by our
Health Minister assure us that our own regulatory arrangements
and purchasing procedures are sufficiently effective to prevent
some of these spurious, counterfeit and substandard drugs
reaching our sales or distribution outlets? If not, would not
the champions of the poor be hitting the poorer segments of
society the hardest?
[Let me plead ‘mea culpa’ for inadvertently typing the
chemical name of the trade name drug Tylenol for that of Valium,
in my previous article.]